US chip export controls stayed off the Xi-Trump summit agenda, analysts say

China's Foreign Ministry announced eight outcomes from the summit, including a new China-US dialogue on artificial intelligence risks.

US Trade Representative Jamieson Greer told CNBC that export control issues tied to national security were not part of this week's trade negotiations. UA.NEWS reported this account on 26 September, and it matches the summaries released by both governments. On 28 September, Export Compliance Daily noted that the US-China economic and trade truce renewed last week is "more fragile than either side is letting on." Former US officials and policy analysts quoted by the outlet expect Beijing to keep pushing Washington to lift export controls and remove Chinese companies from restricted party lists.

Restrictions remain in place

The lack of public argument does not mean the rules were relaxed. The Trump administration has largely kept the controls introduced by Joe Biden's administration in October 2022, which limit Chinese access to advanced chips and the equipment used to make them. Under those rules, advanced integrated circuits, semiconductor manufacturing equipment and related items above specified performance thresholds require a BIS licence for most destinations, according to LawSnap's framework overview, which is current through 27 September 2026. The framework sorts destinations into overlapping tiers.

Close US allies in Country Group A:5 face minimal restrictions. Arms-embargoed destinations in Country Group D:1, including China for the most advanced chip technologies, face near-total restriction with licence applications reviewed under a presumption of denial. Separately, Entity List designations for SMIC and Huawei require a BIS licence for any item subject to the EAR, including EAR99 items.

"The model is drawing a boundary," said Mo Faisal, CEO of Movellus. "It's like, 'Hey, you're getting in the domain that I work in. Stay in your lane.'"

The Foreign Direct Product Rule extends EAR jurisdiction to non-US-made items that are the direct product of US-controlled technology or software, or are produced by equipment that is itself such a direct product. LawSnap cites the Applied Materials case as the clearest enforcement example: BIS issued an is-informed letter on 25 September 2020 covering certain SMIC transactions, and the company later agreed to a $252,500,300 penalty, 56 violations, a three-year suspended Denial Order and two mandatory annual compliance audits under a February 2026 final order.

Analyst calls for AMD investigation

On 24 September, Tom's Hardware reported that Dylan Patel, head of the analysis firm SemiAnalysis, called for a treason investigation into AMD. Patel said China's Puzhi Electronic Technology was crowdfunding a system built on AMD's Zynq UltraScale+ XCZU47DR RFSoC, an export-controlled dual-use component. He wrote that the US list price is $36,000 per chip, with $4,000 to $5,000 to US companies at volume, while it was quoted at $1,000 in China to crowdfunding campaigns.

AMD told Tom's Hardware it did not sell or ship the chips directly into the restricted region. A spokesperson said the company investigates all suspected diversion cases, reports violations to relevant authorities and ceases business with the company involved, without explicitly confirming an investigation into this case. Puzhi positions its systems for "professional engineers" and "advanced researchers in universities," according to the same report, though Tom's Hardware noted such systems can be used for other applications.

China's own supply chain push provides the backdrop. SemiEngineering's 25 September week-in-review reported that the SIA says China is targeting 80% chip self-sufficiency by 2030, with a requirement that chipmakers use at least 50% domestic semiconductor manufacturing equipment and a 20% price advantage for qualifying domestic products in government procurement.

Paul Triolo, a partner at DGA-Albright Stonebridge Group, told the South China Morning Post that the current pause may be temporary. He pointed to legislative efforts in the US Congress, including the Match Act, which is intended to push allies including Japan and the Netherlands to coordinate restrictions on advanced chipmaking equipment sales to China. Triolo said Chinese officials may view new restrictions as a violation of agreements reached in Busan in October 2025 and respond by expanding controls over rare earth metals and the equipment for producing them.

Senate Democrats have kept up pressure in the other direction. Export Compliance Daily reported that four Democratic senators held a news conference on 23 September to urge Majority Leader John Thune to bring up three chip-related export control bills, with no immediate sign they would get a floor vote.